Planning Application: Report of Handling

Agenda Item (E) Planning Application: Report of Handling

Application No. 18/0148/PP

KEY INFORMATION Report by Director of Development and Housing Services

Ward PROPOSAL: ERECTION OF RESIDENTIAL DEVELOPMENT COMPRISING 9 DWELLINGHOUSES WITH ASSOCIATED

8 Johnstone South and ACCESS (IN PRINCIPLE) Elderslie LOCATION: PADUA, OLD HOWWOOD ROAD, HOWWOOD, JOHNSTONE Applicant Blackdye Limited APPLICATION FOR: PLANNING PERMISSION IN PRINCIPLE Midton Lodge Midton road Howwood PA9 1AG

Registered: 26/02/2018

RECOMMENDATION

Refuse.

SUMMARY OF REPORT

• The proposal is contrary to Policy ENV1 ‘Green Belt’ and Policy P2 ‘Housing Land Supply’ as it would undermine the Spatial Strategy of the Fraser Carlin Renfrewshire Local Development Plan as well as the Renfrewshire Local Head of Planning and Development Plan New Development Supplementary Guidance in Housing Delivering the Environmental Strategy.

• The proposal will also result in inappropriate development on the functional floodplain contrary to Scottish Planning Policy and Policy I5 ‘Flooding & Drainage’ of the Renfrewshire Local Development Plan.

• 3 letters of representation have been received raising concerns in relation to development on a green belt site before brownfield, impact on local infrastructure, flood risk and ecology.

Renfrewshire Council Communities, Housing and Planning Policy Board Page 1

RENFREWSHIRE COUNCIL

DEVELOPMENT AND HOUSING SERVICES REPORT OF HANDLING FOR APPLICATION 18/0148/PP

APPLICANT: Blackdye Limited SITE ADDRESS: Padua, Old Howwood Road, Howwood, Johnstone, PA9 1AF PROPOSAL: Erection of residential development comprising 9 dwellinghouses with associated access (in principle). APPLICATION FOR: Planning Permission in Principle

NUMBER OF Three letters of representation have been received. The points REPRESENTATIONS AND raised in the letters can be summarised as follows; SUMMARY OF ISSUES RAISED: (1) Access; (2) Pressure on local infrastructure; (3) Ecology; (4) Proposal is located within the green belt; (5) Development should be directed to brownfield sites; (6) Area is overdeveloped; (7) Flood risk; (8) Traffic; (9) Detrimental impact on amenity of neighbouring properties.

The points raised in the letters of representation have been addressed in the assessment of the application.

Glasgow Airport Safeguarding – No comments. CONSULTATIONS: Director of Environment and Communities

(Traffic) – No comments.

(Design) - Object. Development proposal is in functional flood plain.

(Environmental Services) - No objection subject to condition regarding contaminated land.

PRE-APPLICATION None. COMMENTS:

ENVIRONMENTAL Not applicable. STATEMENT APPROPRIATE Not applicable. ASSESSMENT DESIGN STATEMENT - The applicant has provided supporting information on the proposed development including site location, description and history.

The proposed development is based on the layout, scale and mix of adjacent development at Fordbank. It is stated that the development is located wholly within the boundaries of Johnstone on a low quality parcel of land, and will provide a definitive boundary between the edge of Johnstone and the open amenity land and countryside beyond.

ACCESS STATEMENT – Not applicable.

OTHER ASSESSMENTS – Not applicable.

CLYDEPLAN POLICIES: Not applicable. Proposal is not considered to be of a strategic scale of development.

LOCAL DEVELOPMENT Adopted Renfrewshire Local Development Plan August 2014 PLAN POLICIES/ Policy ENV1: Green Belt OTHER MATERIAL Policy P2: Housing Land Supply CONSIDERATIONS Policy I5: Flooding and Drainage

New Development Supplementary Guidance Delivering the Infrastructure Strategy - Infrastructure Development Criteria, Connecting Places and Flooding and Drainage Delivering the Environment Strategy - Environment Development Criteria, Green Belt and Housing in the Green belt

Material considerations Renfrewshire Local Development Plan Housing Land Supply Supplementary Guidance (2015)

COMMENTS

PLANNING HISTORY None relevant.

SITE VISIT 14/03/2018

DESCRIPTION This application seeks planning permission for the erection of a residential development comprising 9 dwellinghouses with associated access (in principle) on an agricultural field fronting Beith Road on the western edge of Johnstone.

The application site is bound by Beith Road to the north with residential development at Fordbank beyond (approved under planning application 13/0243/PP), residential development to the east (approved under planning application 15/0643/PP), with agricultural fields to the south and west. The site slopes gradually up hill from north west to south east. Boundary treatment is a mix of hedges, post and wire and palisade fencing.

The proposed layout comprises of 9 detached dwellinghouses laid out around a cul-de-sac, with a new access formed onto Beith Road. As the application is in principle only, no further details have been provided.

DESIGN AND MATERIALS The application is in principle only and therefore the majority of these details would require to be assessed through the submission of further planning applications.

SCALE AND POSITIONING The application is in principle only and therefore the majority of these details would require to be assessed through the submission of further planning applications.

PRIVACY AND The application is in principle only and therefore the majority of OVERLOOKING these details would require to be assessed through the submission of further planning applications.

DAYLIGHT AND The application is in principle only and therefore the majority of OVERSHADOWING these details would require to be assessed through the submission of further planning applications.

LANDSCAPING The application is in principle only and therefore the majority of these details would require to be assessed through the submission of further planning applications.

ACCESS AND PARKING No comments.

SITE CONTRAINTS Potential flood risk area.

OTHER COMMENTS Section 25 of the Town and Country Planning (Scotland) Act 1997, requires that planning applications are determined in accordance with the Development Plan unless material considerations indicate otherwise. In addition, the comments of consultees and the issues raised through representations are material considerations in the assessment of the application.

Scottish Planning Policy Scottish Planning Policy sets out national planning policies which reflect Scottish Ministers' priorities for the operation of the planning system and for the development and use of land. SPP aims to support sustainable development and the creation of high quality places.

It sets out two overarching policy principles namely a presumption in favour of development that contributes to sustainable development; and, placemaking which seeks the creation of high quality places.

It considers that the planning system should support economically, environmentally and socially sustainable places by enabling development that balances the costs and benefits of a proposal over the longer term. The aim is to achieve the right development in the right place. It is not to allow development at any cost.

The presumption in favour of sustainable development does not change the statutory status of the development plan for decision making. For proposals that do not accord with development plans, the primacy of the plan is maintained. The presumption in favour of development that contributes to sustainable development is a material consideration.

In this instance, the proposal comprises a development of nine houses on green belt land on the south western edge of Johnstone. The south west of Johnstone has been designated as a community growth area. The Local Development Plan spatial strategy focuses residential development on brownfield sites within the community growth area. In addition, the site is not considered to be effective as it is located within a functional flood plain. Development on the application site would not therefore be considered as sustainable.

On Enabling the Delivery of New Homes, Scottish Planning Policy indicates that the planning system should identify a generous supply of land within the plan area to support the achievement of the housing land requirement across all tenures, maintaining at least a 5 year supply of effective housing land at all times; enable provision of a range of attractive, well-designed, energy efficient, good quality housing, contributing to the creation of successful and sustainable places.

In this regard the Renfrewshire Local Development Plan identified land across the Renfrewshire area to meet the housing land requirements with the focus on brownfield land to meet the majority of the housing land requirements along with a number of green belt release sites to help stimulate supply in the short term. The application site has not been identified through the Renfrewshire Local Development Plan as a site suitable for green belt release.

The Housing Land Supply Supplementary Guidance 2015 was produced in response to an assumed shortfall in housing numbers in order to provide a framework to assess sites which could come forward in the short term to contribute to the housing land supply. The application site does not meet all the requirements set out in the Housing Land Supply Supplementary Guidance 2015.

Local Development Plan policy would not support residential development at this location in principle. Granting of planning permission would undermine the plan making process, and would therefore be contrary to Scottish Planning Policy.

Adopted Renfrewshire Local Development Plan August 2014

Policy ENV1 states that the green belt in Renfrewshire aims to identify appropriate locations to support planned growth, where required, as well as maintaining the identity of settlements and protecting and enhancing the landscape setting of an area. It states that appropriate development within the green belt will be acceptable where it can be demonstrated that it is compatible with the provisions of the New Development Supplementary Guidance.

The New Development Supplementary Guidance on Delivering the Environment Strategy states that proposals for development of residential use in the green belt may only be permitted where it can be demonstrated that the development is justified against the majority of five assessment criteria. When the application proposal is assessed against these criteria, the following conclusions can be made:

The development is required to maintain and support an established activity that is suitable in the green belt; The application proposal is not required to maintain or support an established activity that is suitable in the green belt.

It is demonstrated that there is a need for the residential use to be located out with the settlement; It has not been demonstrated that there is a need for the residential use to be located outwith a settlement.

Buildings which have a special architectural, traditional or historic character may be converted; Not relevant in this instance.

The proposal demonstrates outstanding quality of design; The application is in principle only and therefore the majority of these details would require to be assessed through the submission of further planning applications.

The proposal integrates with, complements and enhances the established character of the area and has no significant impact on the landscape character; The application site is located at the south western edge of Johnstone. The south west of Johnstone has been designated as a Community Growth Area, and there has been recent residential development to the north west and north east of the site by Dawn Homes and Persimmon Homes respectively. This gateway development is of a high standard, and provides a high level of amenity along Beith Road on the approach into Johnstone from the south west. As the application is in principle only, details of design, materials, landscaping etc do not need to be provided.

The applicant has intimated in their design statement that these aspects would likely reflect that of the adjacent developments. However the application has been submitted with a draft layout comprising of nine houses arranged around a cul-de-sac. It is not considered that such a layout would successfully integrate, complement or enhance the character of the area, and would be detrimental to the visual amenity of the gateway into Johnstone

All development within the green belt must also be assessed against the green belt development criteria.

In this instance, there will be no loss of prime quality agricultural land. It is not anticipated that there would be any direct effect on public water supply or water courses from pollution risk, however again it is noted that the site is on the functional flood plain. It is not considered that local landscape character will be maintained or enhanced by the development, and it has not been demonstrated through the information provided that careful consideration has been given to the layout and grouping of buildings. There will be no significant detrimental effect on identified nature conservation interests.

The proposal does not comply with the above criteria as listed in the New Development Supplementary Guidance, and is therefore considered to be contrary to the provisions of Policy ENV1.

Policy P2 'Housing Land Supply' states that the Council will maintain a 5 year supply of effective housing land at all times and prepare Supplementary Guidance including a framework to guide the release of additional housing land where a 5 year supply of effective housing land is not being maintained. Within the Local Development Plan Housing Land Supply Supplementary Guidance (2015), it is accepted that there is an assumed shortfall of private sector housing.

Where a 5 year supply of effective housing land is not being maintained, Policy P2 states that the Council will grant planning permission provided that a number of criteria are met. When the application proposal is assessed against these criteria the following conclusions can be made.

The site is shown to be effective and can be delivered to address the identified shortfall; The site is not considered to be effective as it is located within a functional flood plain. Delivery of houses on the site would therefore be contrary to Scottish Planning Policy on Managing Flood Risk and Drainage.

It will not undermine the spatial strategy of the plan; The proposal does not accord with the adopted Local Development Plan Spatial Strategy, the focus of which is on the development of previously used sites, concentrating on existing built-up areas and key redevelopment sites, aiming to facilitate sustainable development and a low carbon economy. In this instance for example, it is noted that the Johnstone South West Community Growth Area contains six Housing Action Programme Sites where residential development should be targeted as they are at more sustainable locations within the existing urban area.

Its design would comply with the criteria for implementing the spatial strategy; The application is in principle only and therefore these details would require to be assessed through the submission of further planning applications. However as stated above, the layout information which has been received is not considered to successfully integrate, complement or enhance the character of the area.

Further to the criteria in Policy P2, the Local Development Plan Housing Land Supply Supplementary Guidance (2015) also provides a framework for release of further housing land against which residential planning applications are to be assessed. The guidance sets out the circumstances within which the additional release of land for housing will be supported but demands that those sites meet the 'main' and 'other considerations.

It is concluded therefore that the application proposal does not comply with Policy P2 - Housing Land Supply. As stated above, the proposals are not considered to satisfy the 'main' considerations with respect Scottish Planning Policy and the Renfrewshire Local Development Plan Spatial Strategy on the basis that the site is located within a functional flood plain, and that development should be focused on previously used sites within existing built up areas of which there are six within the Johnstone South West Community Growth Area alone.

Similarly, the proposals are not considered to have satisfied all of the 'other' considerations such as the effectiveness of the site, its capacity to be substantially built out by 2019, and the affect on the character and amenity of the surrounding area.

It is concluded therefore that the application proposal does not comply Policy P2 or the framework for release as required by the Local Development Plan Housing Land Supply Supplementary Guidance (2015).

Policy I5 states that new development should avoid areas susceptible to flooding. The Director of Environment and Communities (Design) has objected to the application on the basis that the site is within the functional flood plain. Development of the site would therefore be contrary to Scottish Planning Policy, and the provisions of Policy I5.

With regard to consultation responses that have not been addressed above, the Director of Environment and Communities (Environmental Services) has not objected to the proposed development subject to conditions.

It is concluded that notwithstanding the assumed shortfall of an effective land supply as set out in the Local Development Plan Housing Land Supply Supplementary Guidance (2015), it has not been demonstrated that this is an appropriate site for residential development which would not impact unacceptably on the purposes of the green belt in this location.

The proposal is therefore considered to be contrary to Policy ENV1 and associated New Development Supplementary Guidance. For these reasons it is considered that the proposal cannot satisfy the requirements of Policy P2 and the Housing Land Supply Supplementary Guidance 2015, as the residential development of this site would not comply with the Spatial Strategy of the Local Development Plan. The proposal is also contrary to Policy I5 as the site is located within a functional flood plain.

RECOMMENDATION Refuse

Reasons for Refusal 1 The proposal is contrary to Policy ENV 1 of the Adopted Renfrewshire Local Development Plan in that it would result in development within the designated Green Belt without appropriate justification and due to its location and scale would not be commensurate with the aims of enhancing the character and landscape setting of an area.

2 The proposal is contrary to the Adopted Renfrewshire Local Development Plan New Development Supplementary Guidance - Delivering the Environment Strategy as it does not require a specific green belt location and does not maintain or support an established activity which is suitable in the green belt. The proposal would thereby introduce an inappropriate form of development into the Green Belt, result in an unacceptable erosion of the Green Belt and result in an adverse and detrimental impact on its character.

3 The proposal is contrary to Policy P2 of the Adopted Renfrewshire Local Development Plan and the Housing Land Supply Supplementary Guidance 2015, and due to its scale and location, the proposed development would undermine the Spatial Strategy of the Adopted Renfrewshire Local Development Plan. The proposal would thereby introduce an inappropriate form of development into the Green Belt, result in an unacceptable erosion of the Green Belt and result in an adverse and detrimental impact on its character.

4 The proposal is contrary to Policy I5 of the Adopted Renfrewshire Local Development Plan and the associated New Development Supplementary Guidance - Delivering the Infrastructure Strategy in that it would introduce development into an area susceptible to flooding, and would not therefore accord with the principles of sustainable flood risk management.

Fraser Carlin Head of Planning and Housing

Local Government (Access to Information) Act 1985 - Background Papers For further information or to inspect any letters of objection and other background papers, please contact Sharon Marklow on 0141 618 7835.